Mandatory working time recording in 2027

From 1 January 2027, every Belgian employer should record the working time of its employees. Here is what the text provides, who is concerned and how to prepare.

By Matias Arbesu, founder of Pointly Updated on 3 November 2026 7 min read Preliminary draft law, not yet voted on

In brief

From 1 January 2027, every employer, private or public, should record each day the working time actually performed by its employees.
Employers with no system yet would have until 31 March 2027 to put one in place.
No time clock is required: paper, a spreadsheet or an app will do, as long as the recording is objective and reliable.
Some employees could be excluded, such as management, sales representatives, teleworkers and mobile roles. The list is not final.
The text has not been voted on yet: dates and details may change.

Where does the text stand?

The obligation stems from a judgment of the Court of Justice of the European Union. In 2019, the Court asked Member States to require employers to have an “objective, reliable and accessible” system for measuring each employee's working time. Belgium had not yet done so.

14 May 2019Judgment of the Court of Justice of the European Union (case C-55/18).
25 Nov 2025The federal government decides on the obligation, in the budget agreement.
26 March 2026The preliminary draft law is submitted to the National Labour Council for an opinion.
29 April 2026The Minister of Employment confirms the timetable before the Chamber.
30 Sept 2026The National Labour Council gives its opinion on the preliminary draft: employers and unions disagree (split opinion no. 2.499).
3 Nov 2026Today: the text has been neither voted on nor published in the Belgian Official Gazette.
1 Jan 2027Planned entry into force.
31 March 2027End of the transition period for employers without a system.

Until the law is published, these remain the dates announced by the government. We update this page at every stage.

What you will have to record

According to the preliminary draft, the employer must measure, objectively and reliably, the working time actually performed by each employee, per day and per week.

The time actually worked, not the planned schedule. A rota alone is not enough.
Not necessarily every start, finish and break. A system that starts from the schedule and only notes the differences (an extra hour, leaving early) could be enough.
No required method. No time clock, not even an electronic tool: the choice is yours.
Probably 5 years of retention from the recording, as for other social documents.

The text does not yet say how employees will be able to consult their hours, even though the Court of Justice speaks of an “accessible” system. The unions criticise it for this. The safest course is to make sure your employees can see their hours.

What if I do nothing?

The penalties are not yet known. But even today, an employer without a reliable record is in a weak position when an employee claims overtime: without proof, the court may order the employer to pay it.

Who is concerned?

All employers, in the private and public sectors alike, whatever their size. Nothing suggests an exception for small businesses. A self-employed person without staff is not concerned: the obligation covers salaried employees.

Possible exclusions

According to the social secretariats that have read the preliminary draft, the obligation might not apply to employees whose working time cannot be measured or set in advance, or who decide their own hours:

management staff and positions of trust;
sales representatives;
home workers, teleworkers included;
employees in mobile or itinerant roles.

Do your teams work on the road or on building sites? It is not yet known who the final text will count as “mobile roles”. A worker who follows their team's schedule is not necessarily one of them. In the meantime, don't remove anyone from your recording too quickly, and ask your social secretariat.

The unions dispute these exclusions: the list may still change.

What you already do may be enough

Systems that already measure the time actually worked, objectively and reliably, could be kept. Partena mentions in particular:

flexitime tracking;
the deviations document for part-time employees;
timesheets and the tachograph in transport;
the registered cash register system in hospitality;
Checkin@Work attendance recording in construction and cleaning;
the specific Dimona in agriculture, horticulture and hospitality.

The obligations specific to your sector remain in place.

Paper, spreadsheet or app?

The law lets you choose. What matters: hours actually worked, noted every day, and corrections that are visible. Here are the points to compare for a team that works in the field.

Method	Hours noted	Corrections	The employee sees their hours	5-year retention	Team in the field
Paper sheetAlmost free	Often at the end of the week, from memory	A crossing-out, with no way of knowing who	If they keep a copy	Binders to archive	Yes, if the sheet goes with them
SpreadsheetAlmost free	At the office, after the fact	Rarely visible	If they receive the file	Files to back up	No, it stays at the office
Fixed time clockDevice and software	On arrival and departure	Depends on the software	Depends on the software	With the supplier	No, it stays in place
Phone appSubscription	At the time, wherever they are	Kept in a history, depending on the app	On their phone, usually	With the supplier: check the export	Yes

Whatever the tool, check that you will be able to export your data and keep it for 5 years, even if you switch tools in the meantime.

Checklist: get ready in 7 steps

List your employees and their schedules: fixed, variable, part-time.
Identify those who could be excluded, without removing them too quickly: the final text will decide.
Note what you already record (deviations document, flexitime, Checkin@Work) and ask yourself whether it is reliable.
Choose a method that records the time actually worked each day, and whose corrections leave a trace.
Plan the retention: where the data will be for 5 years, who has access, how to export it.
Inform your employees: how to log their time, who sees their hours, what they are used for. Ask your social secretariat whether your work rules need to be adapted.
Run a trial before 1 January: a month with the whole team, then adjust. Keep an eye on the text, which may still change.

Checklist from the guide pointly.be/en/working-time-recording-2027, updated on 3 November 2026.

Frequently asked questions

Will paper timesheets still be allowed?

Yes, according to the preliminary draft: no method is required, and the recording does not have to be electronic. The sheet must reflect, objectively and reliably, the hours actually worked each day.

Do I need to buy a time clock?

No. The government has said it does not intend to reimpose the time clock. A spreadsheet or a phone app may be suitable.

My employees work from home one day a week. Are they concerned?

Teleworkers, regular and occasional alike, are among the exclusions in the preliminary draft. This exclusion is disputed and may still change.

I'm self-employed, with no staff. Am I concerned?

No: the obligation covers the working time of salaried employees. If you hire a first employee, it will apply to them.

Pointly, for field teams

Pointly is a time tracking app designed in Belgium. Each employee records their hours for the day on their phone, with the timer or by entering them, breaks included, even offline. They find their hours in their calendar. You approve the time entries, every change stays in the history, and you export the monthly report as a PDF.

We are following the bill and will adapt Pointly to its final version.

Try it free Or apply for the pilot programme

Sources

This page summarises public information, up to date as of the date shown at the top. It is not legal advice: for your situation, contact your social secretariat.